Paul H. Wilner | Grossberg Company LLP

Firm Activities

Managing Partner/ Lead Tax Partner
Technical Quality Control, Real Estate and Estate and Gift Taxation
Business and Transactional Consulting
IRS Tax Controversy Matters

Professional Organizations

Served as/on:
Tax Executive Committee, American Institute of Certified Public Accountants (AICPA)
AICPA Tax Executive Committee: Technical Reviewer – Partnership, S Corp., and Individual Tax Committees
Chair NYU annual National Real Estate and Partnership Tax Conference
Chair AICPA’s National Partnership Technical Resource Panel (partnership taxation committee)
Chair AICPA’s annual National Real Estate Tax Conference
Chair AICPA Task Force on Debt Reduction Basis Adjustments
Chair of Greater Washington Society of CPA’s Federal Taxation Committee
Member of AICPA (American Institute of Certified Public Accountants)
Member of AICPA’s Federal Tax Division
Chair of AICPA’s Task Force on Partnership Debt Allocations
Member of AICPA Tax Shelter Regulation Task Force
Member of Executive Committee, Jeffrey Henry International; Region of the Americas

Professional Development

Expert Witness Testimony before Treasury
Expert Witness for criminal and civil taxation matters
Author
Relief for Real Estate Professionals From Passive Activity Loss Rules,
TAX IDEAS, Warren, Gorham & Lamont
Disguised Sale Rules, §707(A), Taxation for Accountants, WG&L
Associated Accounting Firms International Booklet on Tax Aspects of Domestics Relations
Jeffreys Henry International Tax Planning Opportunities Guide
Associated Accounting Firms International, Year End Tax Planning Strategies

Lecturer/Instructor

The College of William and Mary, School of Law
NYU Real Estate and Partnership Tax Conferences
D.C. Bar / GWSCPA Pass-through Taxation Division
GWSCPA on Taxation of Real Estate
D.C. Bar Residential Property Committee
Kentucky Institute of Taxation
AICPA National Conference on Taxation and National Real Estate Tax Conference
MICPEL Annual Tax Seminar
Guest Instructor / Lecturer numerous other seminars on Taxation and Business
Listed in Washingtonian Magazine as one of the Top Tax Accountants in Washington D.C.

Career Experience

Comprehensive Tax Planning for High Net Worth Individuals and Family Groups
Specialization in Partnership Taxation and all phases of Real Estate Industry and related fields
Estate, Gift and Trust Taxation
Transactional Tax and Business Consulting
Business and Real Property Acquisition Due Diligence Analysis

Brian J. O’Connor | Venable LLP

Brian O’Connor co-chairs the Tax and Wealth Planning Group for the national law firm of Venable and practices in its Baltimore, MD, Washington, DC and Tysons Corner, VA offices. In addition to his role of managing the Tax and Wealth Planning Group, Mr. O’Connor provides sophisticated tax and business advice to publicly-traded and closely-held businesses and their owners. His practice focuses on foreign and domestic tax matters for partnerships, limited liability companies, joint ventures, both C and S corporations, real estate investment trusts (“REITs”) and regulated investment companies (“RICs”). He is also regularly consulted by wealthy individuals and entrepreneurs on federal and state income tax matters and federal estate and gift tax issues.

Mr. O’Connor is an adjunct professor in the graduate tax program at Georgetown University Law Center where he teaches an advanced course on partnership taxation and the preparation of partnership and limited liability company agreements. Before joining Venable, Mr. O’Connor was an attorney-advisor for the Office of Chief Counsel for the Internal Revenue Service in Washington, DC where he worked on high profile legislative projects, regulations and other published guidance relating to partnerships, S corporations, trusts, common trust funds and cooperatives. Mr. O’Connor received his J.D., Magna Cum Laude, from Washington and Lee University and his LL.M., with distinction and the program’s highest possible grade point average, from Georgetown University Law Center.

Glenn M. Johnson | EY National Tax

Glenn is a Principal in Ernst & Young LLP’s US National Tax Department. Glenn leads the US PPP Infrastructure Tax Practice and is the Director of the Leasing Tax Services. Glenn is experienced in planning leasing and other asset-based structured transactions. Also, Glenn has provided US tax services with respect to many infrastructure projects where he advises on a wide range of tax issues to both developers and owners. In addition, Glenn has worked with domestic and foreign manufacturers in establishing and operating captive leasing and finance companies. Further, Glenn has significant experience concerning deferred like-kind exchange transactions where he advises on a wide range of tax and operational issues.

Glenn, who joined Ernst & Young in 1998, earned his LL.M. in Taxation from Georgetown University Law School; his J.D., with honors, from Boston University School of Law; and his B.A. in Economics from Wesleyan University. Glenn also is active in a number of civic and charitable organizations.

Glenn currently is and has been a member of the Equipment Leasing and Finance Association Federal Tax Committee for over 13 years. Glenn is the former American Bar Association Chair of the Capital Recovery and Leasing sub-committee. Glenn is a member of EY’s Federal Income Tax Committee and leads EY’s Infrastructure Tax Committee.

Robert D. Schachat | BDO USA, LLP

Bob has more than 40 years’ experience advising clients in all federal income tax aspects of real estate, including REIT, partnership, limited liability company and S corporation formations, acquisitions, like kind exchanges, development, leases, financings, workouts, dispositions and liquidations. He has also advised clients on a regular basis in monitoring federal legislative and regulatory activity in the real estate area.

Bob joined BDO in 2021 after 23 years in the National Tax Real Estate Group of a big four accounting firm and 12 years as a partner in a Manhattan law firm practicing in the taxation of real estate. Bob has published many articles and lectures frequently at many real estate industry and tax conferences. He is co-author with Jim Lowy of the CCH treatise, Taxation of REITs and UPREITs.

Bob has served as Chair of the Real Estate Committee of the ABA Section of Taxation, Vice Chair of the Tax Policy Advisory Committee of the Real Estate Roundtable and cochair of the Cost Recovery Committee and as a member of the Executive Committee of the NYSBA Tax Section, and he continues to serve as a member of the Government Relations and Real Estate Committees of the ABA Section of Taxation.

Steven R. Schneider | Stroock & Stroock & Lavan LLP

Steven is a nationally recognized tax lawyer who focuses his practice on transactional, controversy and tax policy matters. He has significant tax experience in mergers & acquisitions, private equity and real estate funds, qualified opportunity zone funds, bioscience, cross-border tax, partnerships, real estate, REITs, international investors (including sovereigns), and S corporations.

He started his career as a lawyer in the IRS’ national office and has had many years of national-level law firm and Big-4 accounting firm experience. Mr. Schneider also previously chaired the ABA Partnership Tax Committee. He has been teaching an advanced tax course on drafting partnership and LLC agreements at Georgetown University Law Center since 2005, is a regular speaker at national tax venues, and has published numerous articles.

Andrea M. Whiteway | Principal at Ernst & Young

Andrea Macintosh Whiteway is a principal in the National Tax Department of Ernst & Young LLP, based in Washington, D.C. She has substantial experience in sophisticated tax planning involving the use of partnerships, including in the dispositions and acquisitions of real estate and operating businesses, complex partnership transactions, real estate investment trust (REIT) tax status and tax structured dispositions of real estate involving REITs, corporate acquisitions and mergers, corporations and structuring private REITs.

Andrea advises on forward and reverse like-kind exchanges and exchanges of tenancy in common interests in real estate. Andrea has been listed in the 2008 to 2017 editions of The Best Lawyers in America in the area of tax law and has also been selected as a fellow of the American College of Tax Counsel. She is ranked by The Legal 500 United States and Chambers USA as a leader in her field. Washingtonian Magazine named her as one of the top lawyers in Washington, D.C.

Andrea is also recognized in Washington D.C. Super Lawyers. She is AV rated by MartindaleHubbell and has the highest rating by AVVO. Andrea had the honor of being the first woman to serve as chair of the Real Estate Committee of the American Bar Association Section of Taxation and currently serves on the Section of Taxation Nominating Committee. She also serves as Chair of the Federal Taxation of Real Estate Committee of the American Bar Association Section of Real Property, Trusts and Estates. She serves on the Advisory Board of the NYU Institute on Federal Taxation. She is also a former member of the steering committee of the District of Columbia Bar Section of Taxation and a past Chair of its Passthroughs and Real Estate Committee.

Andrea is an active member of Urban Land Institute. She also serves on the Tax Policy Advisory Committee of the Real Estate Roundtable  and is a member of the National Association of Real Estate Investment Trusts. Andrea is the author of over 100 professional articles and has delivered more than 100 lectures on tax topics at conferences across the United States, including at the Tax Executives Institute, NYU Federal Tax Institute, Texas Federal Tax Institute, Tulane Tax Institute, ABA Tax Section Meetings, AICPA Conferences, ALIABA and Practising Law Institute seminars, University of Texas School of Law Tax Conference, Federal Bar Association and District of Columbia Bar Association programs. Andrea was recognized as one of Maryland’s Top 100 Women for 2007 by The Daily Record which presents this award to “high-achieving Maryland women who are making an impact through their leadership, community service and mentoring.”

James B. Sowell | KPMG LLP

Mr. Sowell is a former chairman of the Real Estate Committee of the American Bar Association (Tax Section) and a former vice chairman of the Tax Policy Advisory Committee of the Real Estate Roundtable. He is a member of the National Association of Real Estate Investment Trusts, where he is an active participant on the Government Relations Committee.

Mr. Sowell also is on the Board of Trustees for the Southern Federal Tax Institute, where he formerly served as President. Mr. Sowell has written articles for various publications and speaks at numerous conferences.

Before joining KPMG, Mr. Sowell was with the national tax offices of other major accounting firms. Prior to that time, Mr. Sowell was with the U.S. Department of Treasury (Office of Tax Policy) where he served first as an attorney advisor and then as an associate tax legislative counsel.

While at the Treasury Department, Mr. Sowell was primarily responsible for administrative guidance and legislation involving partnerships, real estate investment trusts, like-kind exchanges, and other issues. The many matters that Mr. Sowell was involved in while at Treasury included the regulations relating to partnership mergers and divisions, the partnership basis adjustment regulations, the regulations relating to amortization of intangible property, and the legislation relating to taxable REIT subsidiaries. Prior to the Treasury Department, Mr. Sowell was an associate at King & Spalding LLP in Atlanta, Georgia. Mr. Sowell was chief tax editor of the Florida Law Review and was a graduate editor of New York University’s Tax Law Review.

Adam S. Feuerstein | PricewaterhouseCoopers

Adam is the National Real Estate Tax Technical Leader at PricewaterhouseCoopers, LLP and, in that role, he helps clients navigate the complicated tax world in which we live. Adam brings his experience and passion (yes, passion for tax) to help clients see the big picture from a tax perspective, while at the same time keeping an eye on the important details necessary to achieve the client’s particular objectives. Clients often comment that Adam has a keen ability to convey complicated tax concepts and that he is approachable and easy to work with.

Adam has brought his practical business approach to assist sponsors of, and investors in, real estate funds on a wide range of formation and investment matters. He brings this approach to provide guidance and counsel to some of the most well-known fund families in connection with their acquisitions and to help design fund structures that address the various tax issues that affect fund sponsors and their investors.

Adam also regularly advises many public and private REIT clients through their life cycle. In that capacity, Adam has worked on many REIT monetization, conversion and M&A transactions, PropCo/OpCo structures and IPOs and regularly works with REIT clients to address their day-to-day tax matters. Adam is a co-author of the treatise on Real Estate Investment Trusts for RIA’s Catalyst series and is a Contributor to the Guide to Global Real Estate Investment Trusts. He has also served as a faculty member for the Practicing Law Institute sessions for the Real Estate Tax Forum and the Real Estate M&A and REIT Transactions and has spoken on panels at REITWise.

Adam not only has a passion for tax and providing assistance to clients but also enjoys mentoring younger tax professionals. In that vein, Adam has served as an adjunct professor at the Georgetown University Law Center and the Villanova University School of Law where he has taught classes on partnership taxation and the unrelated business income tax.

Adam graduated from Harvard Law School, cum laude, has a Masters in Public Policy from Harvard University’s John F. Kennedy School of Government and received his B.S. with honors from Cornell University.

Adam is an active member in the Tax Policy Advisory Committee of the Real Estate Roundtable and the National Association of Real Estate Investment Trusts. In his spare time, Adam enjoys spending time with his family, playing cards and board games, tennis, bicycling and movies.

Ryan P. McCormick | The Real Estate Roundtable

Ryan McCormick is Senior Vice President and Counsel at The Real Estate Roundtable, where he oversees tax policy activities. The Real Estate Roundtable brings together leaders of the nation’s top real estate ownership, development, lending and management firms and leaders of major national real estate trade associations to jointly address key national policy issues. Most recently, Ryan coordinated industry-wide advocacy efforts in Washington focused on tax reform legislation. Ryan joined the Roundtable in 2013 after serving nearly 11 years in the U.S. Senate as a tax and economic policy advisor for Senators Daniel Patrick Moynihan, John Kerry, Joseph Lieberman, Bob Graham, and Bill Nelson.

He also served as Staff Director of the Senate Finance Subcommittee on Fiscal Responsibility and Economic Growth. Previously, Ryan practiced tax law at Miller & Chevalier in Washington, D.C., the oldest tax law firm in the country. He is a graduate of Georgetown University (BS); Sciences-Po in Paris, France (CIEP); and the University of Texas School of Law (JD). From 2000 to 2001, Ryan researched tax reform in West Africa as a Fulbright Scholar.

David Friedline | Deloitte Tax LLP

David is a partner in our New York office and is the leader of Global Funds Tax Advisory Services Group and the Homebuilding Industry Group. He has a nationwide practice with over 30 years of real estate, private equity, and infrastructure industry experience serving a wide variety of closed and open-end funds, public REITs, and home builders. David has a very practical and commercial approach to serving clients having served for several years as senior tax counsel and tax director to the London and Stamford offices of GE Capital.

David has vast experience advising clients on the U.S. tax aspects of a wide array of domestic and cross-border investments, including formation of partnerships and joint ventures, M&A transactions and due diligence, capital raising and fund-formation, debt-workouts and purchases of debt portfolios, leasing and tax-deferred exchanges, real estate securitizations, and separate accounts. He commonly advises investment managers on the unique tax considerations of institutional investors, including FIRPTA, ECI, the Section 892 and qualified foreign pension fund exemptions, and UBTI and common strategies to manage associated risks.

David is very active in both the Real Estate Committee of the American Bar Association’s Tax Section, for which he is Chair of the Subcommittee on Cancellation of Debt, and in the Tax Policy Advisory Committee of Real Estate Roundtable. David has been a speaker at programs and conferences for the Practicing Law Institute, ABA Tax Section, AICPA, AFIRE, USC Tax Institute, Real Estate Roundtable, NCREIF, New York Private Equity Network and has authored articles on a variety of partnership, international, and real estate tax topics for the Journal of Real Estate Taxation, Journal of Taxation of Financial Products Financial Products, and Major Tax Planning. He serves on the editorial board of the Journal of Real Estate Taxation and is a former Adjunct Professor of Partnership Taxation at Fordham University.

David obtained his accounting degree from Florida State University, College of Business, J.D. (with honors) from American University Law School, and studied tax law at Georgetown University Law Center.

Farhad Aghdami, Esq., Partner | Williams Mullen

Farhad Aghdami is Williams Mullen’s Richmond Managing Partner. He focuses his practice on wealth transfer tax planning, business succession planning, income tax planning for individuals and businesses and fiduciary litigation. He counsels a wide variety of clients, including high net worth individuals and families, middle market business owners, institutional fiduciaries, family offices and charitable entities. Farhad has been listed (Band 1) in the Chambers USA High Net Worth Guide for Private Wealth Law (2017-present).

Farhad serves on the board of directors of the Mutual Assurance Society of Virginia, a mutual property and casualty insurance company, and on the board of a privately held, third-generation construction materials business based in Raleigh, N.C.

Farhad is the Southeast region chair of the American College of Trust and Estate Counsel (ACTEC) and is a member of its Board of Regents. He is chair of the ACTEC Fiduciary Income Tax Committee, the State Chairs Steering Committee, and a member of the Business Planning Committee. He is the immediate past Virginia State chair of ACTEC.

He is listed in The Best Lawyers in America® and was named the Richmond “Tax Lawyer of the Year” in the 2015, 2018 and 2024 editions and the Richmond “Trusts and Estates Lawyer of the Year” in the 2016 and 2019 editions. In addition, Farhad has been named one of the top 50 lawyers in Richmond and one of the top 100 lawyers in Virginia by Virginia Super Lawyers (2012-2015, 2017-present) and was elected to the National Association of Estate Planners & Councils Estate Planning Hall of Fame® Class of 2024. Farhad previously served as an adjunct professor at the University of Richmond School of Law and Washington & Lee’s School of Law.

Farhad serves on the board of trustees of the Southern Federal Tax Institute. In addition, Farhad has held leadership positions in a number of professional organizations, including the Virginia Bar Association’s Wills, Trusts, and Estates Section (chair, 2011-2013), where he led efforts to enact the Virginia decanting statute, the Virginia self-settled spendthrift trust statute, the Virginia grantor trust tax reimbursement statute and the Virginia directed trust statute. In addition, he served as the chair of the Fiduciary Income Tax Committee of the ABA Tax Section (2003-2005). Farhad chaired the ABA Tax Section’s Task Forces that submitted comments on the regulations promulgated in response to the Supreme Court’s decision in Estate of Hubert and in response to IRS Notice 2011-101 on trust decanting.

In addition, Farhad has also served leadership roles in a number of other professional organizations, including the Estate Planning Council of Richmond (President, 2011-2012), Insurance Planning Committee of the ABA Real Property, Probate & Trust Section (chair, 2003-2004), Trust Administrators Council of Richmond (president, 2004-2005), University of Richmond Estate Planning Advisory Council (chair, 2004- 2009) and Richmond Private Business Study Group (chair, 2001-2002).

Farhad is a co-author of three tax treatises published by Thomson Reuters: Structuring Buy-Sell Agreements, Tax Planning for Family Wealth Transfers During Life and Tax Planning for Family Wealth Transfers at Death. He has authored numerous articles that have appeared in tax journals, including The Tax Lawyer and The Journal of Taxation, and he has been quoted in The New York Times and Virginia Business. Farhad is the planning chair of the Conner-Zaritsky Advanced Estate Planning Institute. In addition, he regularly speaks at advanced planning conferences, including those sponsored by the University of Miami-Heckerling Institute, ACTEC, the Southern Federal Tax Institute, the ABA Tax Section, the ABA Real Property, Trust and Estate Section and the American Law Institute.

Farhad is a member of the board of directors of the Virginia Museum of Fine Arts Foundation and Venture Richmond, where he serves as its chair. He is a member of The Forum Club and the 2006 Class of Leadership Metro Richmond. Farhad previously served as chairman of the Board of Governors of the Community Foundation for a Greater Richmond, and he previously served on the Boards of the Valentine Museum, St. Christopher’s School, the Medical College of Virginia Foundation, and the Boys and Girls Club of Metro Richmond.

Farhad is a 1989 graduate of the University of Virginia and a 1992 graduate of the Wake Forest University School of Law. He received his LL.M. in taxation from Georgetown University Law Center in 1995.

George Manousos, CPA, Partner | PricewaterhouseCoopers LLP

George Manousos is a partner in the Federal Tax Services group of the Washington National Tax Services practice of PricewaterhouseCoopers LLP in Washington, DC. George assists clients on general federal tax issues, and specializes in the area of tax accounting including all areas of accounting methods, the timing of income and deductions, depreciation and amortization, capitalization issues, merger and acquisition transaction costs, tangible property “repair” costs, and requests for accounting method changes with the Internal Revenue Service National Office. In addition, George is the national leader of PricewaterhouseCoopers LLP’s Section 199 practice, and spends a significant amount of time consulting with clients, and representing clients before the IRS, on Section 199 issues.

George earned a B.S. in Business Administration, magna cum laude, from Northeastern University in Boston, MA, and an M.S. in Taxation, with honors, from American University in Washington, DC. A member of the AICPA and a Certified Public Accountant licensed to practice in Massachusetts and the District of Columbia, George serves as an adjunct professor for the graduate tax program at American University’s Kogod School of Business and is a frequent guest speaker on behalf of many professional organizations. George is also co-author of the BNA Tax Management Portfolio 572 – Accounting Methods -Adoption and Changes.

Miriam L. Fisher, Esq., Global Chair of Tax Controversy | Latham & Watkins

Miriam Fisher is Global Co-Chair of the Tax Controversy Practice of Latham & Watkins, and her practice focuses on federal and state tax controversy and litigation.

Miriam has an active tax litigation practice in federal and state trial and appellate courts, where she successfully represents domestic and multi-national businesses, non-profits, and high global wealth individuals in disputes involving a wide variety of sophisticated tax matters.

At the examination and appeals stages of tax controversies, Miriam achieves client goals through good communication, strong substantive and procedural knowledge, innovative, resolution-oriented strategies, and litigation-preparedness. She is highly regarded by clients and peers for her ability to lead trial teams in complex tax litigation and to navigate negotiation and resolution of sensitive, high-stakes disputes.

Miriam also handles sensitive tax matters involving allegations of fraud and helps clients avoid severe penalties and potential criminal charges. She often leads clients through voluntary disclosure and correction of compliance errors.

Miriam frequently speaks and writes on issues involving tax procedure, policy, and ethics. She is admitted to practice before the US Tax Court, various US District Courts, US Court of Federal Claims, and the US Courts of Appeals for the Second, Third, Fourth, and Federal Circuits.

Miriam is consistently ranked as a leading tax lawyer by Chambers USA. Sources describe her as “professional, responsive, practical, articulate, confident, and mindful of budgets” with “world class” tax controversy and litigation experience (Chambers USA 2017), also noting, “she’s 100% the kind of attorney that both sides want (Chambers USA 2018). In 2018, The American Bar Association Tax Section Civil and Criminal Tax Penalties Committee honored Miriam with the Jules Ritholz Memorial Merit Award. She was named Best Lawyers’ Lawyer of the Year in Washington, D.C. for Litigation and Controversy – Tax in 2017 and 2019. She is also recognized as one of the elite leading lawyers inducted to The Legal 500’s Hall of Fame, which includes fewer than 500 partners across the US “who have received constant praise by their clients for continued excellence,” in 2018. She has been recognized as a Tax Controversy Leader by the International Tax Review 2018, an annual guide that identifies leading tax lawyers and advisers based on nominations from hundreds of global tax directors and CFOs.

Jason B. Grover, Esq., Counsel | Latham & Watkins

Jason Grover resolves highstakes disputes with the IRS on behalf of clients facing intractable tax controversies across a wide range of substantive issues. Jason pursues strategic solutions for taxpayers — including the world’s largest corporations, emerging companies, and high-net-worth individuals — in all stages of federal tax controversies by navigating:

• Complex audits, including those involving potential criminal exposure
• Contentious IRS Independent Office of Appeals conferences
• Litigation before the US Tax Court, US Court of Federal Claims, and US district courts

He helps clients secure the optimal outcome of a dispute, whether through creative IRS settlement or dogged litigation. Jason leverages particular knowledge on the procedural and substantive aspects of partnership audits, both under the legacy TEFRA regime and under the new BBA rules, to guide clients in this evolving landscape.

A recognized thought leader, Jason frequently writes on tax matters and speaks before the American Bar Association, Federal Bar Association, and other professional associations. He maintains an active pro bono practice, through which he serves individual low income taxpayers. Before joining Latham, Jason worked in another global law firm’s tax controversy practice.

DAY 1: THURSDAY, JUNE 12

Welcome | 8:25am – 8:30am

SHIFTS IN SHARING OF APPRECIATION OF PARTNERSHIP ASSETS AND CRYSTALLIZATION OF PROMOTE INTERESTS | 8:30am – 9:30am

Subject to a varying interest rule, the allocations under a partnership agreement can be amend through the original filing date of the tax return, retroactively to the first day of the tax year. However, there is not significant guidance with respect to current year shifts in the appreciation in assets that occurred in a prior year. This session addresses the significant complexity in these types of possible capital shifts and the impact of these concepts on Carried/Promote interests as well as the issues related to the crystallization of existing claims in such appreciation.

Paul H. Wilner, CPA, Advisor, Grossberg Company, Bethesda, MD

Brian J. O’Connor, Esq., Partner, Venable, Washington, DC

ESTATE PLANNING FOR REAL ESTATE | 9:30am – 10:30am

The presentation focuses on the management and ownership of a real estate entrepreneur’s assets in ways best attuned to minimizing estate and gift taxes. The discussion includes forms of ownership and real estate entity restructuring, succession concerns, state law issues, and gifting and/or sales techniques that are particularly well-suited for real estate owners as well as methods of providing for the payment of estate taxes in the most cost and tax-efficient.

Farhad Aghdami, Esq., Partner, Williams Mullen, Richmond, VA

Break | 10:30am – 10:45pm

LEASING PROPERTY IN A TROUBLED REAL ESTATE ENVIRONMENT | 10:45pm – 12:00pm

The federal income tax ramifications from different Landlord/Tenant lease negotiation incentives and structures in a tenant favorable market, including: rent reductions; rent holidays; tenant inducement payments; tenant allowances; and landlord improvements.

Glenn M. Johnson, Esq., Principal, EY, Washington, DC

Robert D. Schachat, Esq., Managing Director, BDO USA, Washington, DC

Lunch | 12:00pm – 1:00pm

POST-LUNCHEON ADDRESS: ASK THE EXPERTS | 1:00pm – 1:45pm

This session provides an outstanding opportunity for the audience to raise tax questions with a panel of leading experts.

Glenn M. Johnson, Esq., Principal, EY, Washington, DC

Brian J. O’Connor, Esq., Partner, Venable, Washington, DC

Robert D. Schachat, Esq., Managing Director, BDO USA, Washington, DC

Steven R. Schneider, Esq., Partner, Hogan Lovells, Washington, DC

Andrea M. Whiteway, Esq., Principal, EY, Washington, DC

Paul H. Wilner, CPA, Advisor, Grossberg Company, Bethesda, MD

COMPLEX ISSUES IN DRAFTING PARTNERSHIP AGREEMENTS | 1:45pm – 3:00pm

This panel discusses the top items of negotiation between joint venture parties as well as the mistakes the panelists see in partnership agreements. Topics include partnership debt planning, built-in gain allocation negotiations, tax distributions, and audit provisions. The presenters each have decades of experience in negotiating and drafting agreements and are frequent authors and speakers on this topic.

Brian J. O’Connor, Esq., Partner, Venable, Washington, DC

Steven R. Schneider, Esq., Partner, Hogan Lovells, Washington, DC

Break | 3:00pm – 3:15pm

HOT TOPICS IN LIKE KIND EXCHANGES | 3:15pm – 4:30pm

This panel covers a wide variety of recent developments and trends involving like-kind exchanges of real property, including partnership split-ups, parking arrangements within and outside the safe harbor, construction exchanges, leases, pre- and post-exchange debt refinancing, transfers in foreclosure and related party transactions.

Glenn M. Johnson, Esq., Principal, EY, Washington, DC

Robert D. Schachat, Esq., Managing Director, BDO USA, Washington, DC

TROUBLED BUSINESS WORKOUTS | 4:30pm – 5:30pm

This presentation covers the issues associated with troubled businesses and debt restructuring/workouts with a focus on partnerships and real estate.

James B. Sowell, Esq., Principal, KPMG, Washington, DC

DAY 2: FRIDAY, JUNE 13

CREATIVE DEAL STRUCTURES | 8:45am – 10:00am

This session covers creative real estate deal structures related to transactions involving both the entry and exit from joint ventures, recapitalizations, revaluations, preserving negative capital accounts, debt and equity planning, REIT planning, and other tax-focused transactional planning.

Andrea M. Whiteway, Esq., Principal, EY, Washington, DC

Adam S. Feuerstein, Esq., Principal, PwC US Tax, Washington, DC

TAX PLANNING UNDER TAX ACCOUNTING METHODS | 10:00am – 11:00am

This panel discusses hot topic accounting method opportunities to optimize cash flow, as well as strategic considerations and planning actions to begin analyzing now in advance of potential tax reform legislation in 2025.

George Manousos, CPA, Partner, PwC US Tax, Washington, DC.

Break | 11:00am – 11:15am

THE NUTS AND BOLTS OF NAVIGATING PARTNERSHIP AUDITS | 11:15am – 12:15pm

This presentation discusses navigating BBA partnership audits — already among the lengthiest and most complicated IRS administrative proceedings — which are only going to get more challenging given recent changes at the IRS. This session provides guidance on how to efficiently and effectively navigate BBA audits in a  time of IRS staffing uncertainty and changing agency priorities.

Miriam L. Fisher, Esq., Global Chair of Tax Controversy, Latham & Watkins, Washington, DC

Jason B. Grover, Esq., Counsel, Latham & Watkins, Chicago, IL

Lunch | 12:15pm – 1:15pm

POST-LUNCHEON ADDRESS: LEGISLATIVE OUTLOOK FOR REAL ESTATE | 1:15pm – 2:15pm

This presentation focuses on current key national public policy issues and legislative actions under consideration as they affect the real estate industry as well as the overall economy.

Ryan P. McCormick, Esq., Senior Vice President and Counsel, The Real Estate Roundtable, Washington, DC

CREATIVE PLANNING FOR CROSS-BORDER REAL ESTATE INVESTMENT | 2:15pm – 3:30pm

This presentation discusses structures to own US real estate in a tax efficient manner, special concerns when a non-US person becomes a partner in a partnership or investment fund owning US real estate or mortgage debt and use of related party debt to reduce US tax exposure.

David Friedline, Esq., Partner Deloitte Tax, New York, NY

Adam S. Feuerstein, Esq., Principal, PwC US Tax, Washington, DC

Break | 3:30pm – 3:45pm

COMPLEXITIES IN PARTNERSHIP DEBT ALLOCATIONS | 3:45pm – 5:00pm

This presentation focuses on how the partnership debt allocation rules operate in entities structured as partnerships and limited liability companies, including a discussion of the recent final related party debt allocation regulations.

Andrea M. Whiteway, Esq., Principal, EY, Washington, DC